LINKWOOD — At a public hearing held recently by the Maryland Department of the Environment (MDE) at the Dorchester County Library meeting room, the delicate and often contentious balance between public interest groups, government environmental regulators, and businesses, was apparent. The topic was a request to renew a permit to discharge treated wastewater to “surface waters” adjacent to the Valley Protein plant in Linkwood.
Led by Michael Richardson, division chief of the Industrial Permits division of the MDE, the meeting gave the environmentalist community an opportunity to question executives of Valley Protein regarding the potential impact of increased discharges. And question they did. Each side was well prepared to ask appropriate questions and give appropriate answers.
Valley Proteins gathers inedible waste from slaughtering operations, provides dead animal collection, and collects used cooking grease and bones from restaurants and supermarkets. The company turns these waste products into liquid fats, oils, and protein meals for agricultural and pet-food manufacturing, and biofuel producers.
The application seemed like two separate issues. First, was a renewal of its permit to discharge up to 150,000 gallons of processed wastewater from its poultry rendering facility to what MDE called “an unnamed tributary to Higgins Mill Pond to the Transquaking River.” Second was a “modification” to the original permit that would raise the maximum discharge up to 575,000 gallons a day. The company plans to double its production quotas and a modification was necessary to accommodate the increase.
From the MDE’s viewpoint the “centerpiece” of the 1974 Clean Water Act is the wastewater discharge permit for which it is responsible. The permit establishes the standards for “acceptable pollutant levels or defines management practices to achieve that end” based on state regulations. The goal is to keep the streams, creeks, and other “receiving waters” clean enough for aquatic life and/or human or animal contact.
The meeting could have been adversarial – the “bad guys” vs the “good guys” with the MDE in the middle. It was not. Several well-known non-profit groups were represented, including Mid-Shore River Conservancy, Choptank Riverkeepers, Dorchester Citizens for Planned Growth, the Chesapeake Bay Foundation, and the Department of Natural Resources. These groups seek to reduce watershed pollution that affects the health of the Chesapeake Bay watershed.
Representing Valley Protein were Robert Vogler, Director of Environmental Affairs; Mike Smith, Vice Pres. of Operations; John Reid and Wade Tanner, project designers from Reid Engineering; Neil Gagnon, district manager; Ernie Roten, plant manager; and Reed Parks, general manager.
The original permit, according to MDE engineer Robert Pudmerecky, was issued in 2001 and expired in 2006. He explained that wastewater discharge is pre-treated in several stages before it leaves the lagoons and even if a permit has expired the TMDL limits remain.
TMDL (Total Maximum Daily Loads) is a casually and frequently used acronym that is not self-explanatory. “Load” is the total number of pounds of polluting materials in wastewater. A TMDL adds up all the waste load allocations for so-called “point sources” like sewage treatment plants, storm water discharges, etc., plus non point sources like rain, farms, etc., plus a margin of safety to make sure the receiving water meets quality standards.
Mr. Pudmerecky spent 45 minutes specifying the required standards and reportable pollutant numbers in discharged water required to maintain a permit.
He also noted Special Conditions that “are tailor-made for this particularly permit.” They include: A sludge management plan, odor control requirements, compliance plans for nitrogen limits and groundwater nitrates, groundwater monitoring plan, annual average loading limit of 41 lbs/day for nitrogen, bio-monitoring, and a storm water pollution prevention plan for each area generating storm water industrial wastewater.
The plant wants to increase production to 20 million pounds per week of raw material and increase the discharge. Mr. Pudmerecky noted that much of the flow is re-circulated throughout the plant and not discharged. He emphasized that with the planned upgrades, “the water quality will still be protected.”
An audience member asked if the MDE knows about “the persistent algae blooms in Higgins Mill Pond and downstream of the plant.” Mr. Richardson said yes, and promised to determine if the facility “plays a part in the water quality problem. The final permit will reflect the decision.” The questioner noted that water quality study data is readily available.
Several in the audience noted they thought it was part of the MDE’s role to determine whether the river is meeting the designated use. Mr. Richardson responded that “If the problem is with other inputs to the water body, I can’t deal with that with this one permit.”
Valley Proteins Director of Environmental Affairs Bob Vogler said the company, founded in 1949, is one of the largest independent recyclers in the country and recovers thousands of pounds of material that would otherwise fill landfills. The Linkwood company purchased the plant in 2013 and employs 85 area residents.
According to Mr. Vogler, the company plans a $10 million investment in equipment and technology. Changes include: Converting an anaerobic treatment to aerobic; adding pre treatment removal solids; adding a new final clarifier, sand filter process to remove phosphorus; installing a new ultraviolet disinfecting system that does not require the use of chlorine; constructing a new wastewater building, a new storage tank, retrofitting existing tanks, installing new aerators, pumps, other equipment; providing new controls for operating and monitoring the system.
Asked why the permit raises the discharge maximum to 575,000 gallons, he explained. “That amount will probably never be discharged, but we’ll have to treat that amount as we expand the plant. We’re treating to such stringent requirements we use the water back in the facility for cooling and washup purposes and recycling.” They plan for extra discharge capabilities in the event of excessive rain “so we don’t release more than our permitted amount.” Mr. Vogler estimated a daily total discharge of 300,000 based on doubling the size of the rendering plant.
Roman Jesian, volunteer with the Dorchester Citizens for Planned Growth, explained that the stream normally has little water in it and said “you’re discharging over 100% of that stream.” Mr. Jesian admitted that the facility is not the only source of pollutants but explained that downstream of the plant the river is highly polluted with “no contact” signs posted.
Mr. Smith responded, “We’re not the only source of nitrogen on the Eastern Shore. The farmers are dealing with it. Our goal is to meet or beat our current levels which are the lowest in the country.” About 25-30% of the 575,000 will be recycled and the flow should be around 300,000 gallons, but with a heavy rain it will change.
What happens to the solids extracted from the waste? Some wondered if it was stored or spread on farmland. Mr. Smith explained that the solids obtained from a belt press in the lagoons, are injected into soil, not sprayed and are handled by an approved, permitted contractor.
The company extracts 75-100,000 gallons daily from groundwater because they cannot use recycled water in the boilers. Asked where the phosphorus and nitrogen comes from, Mr. Smith explained that organic compounds come from the condensers.
The environmental groups agreed, the meeting “was very helpful to us.” However, one member asked, “if everything is so hunky dory in this watershed why is the quality so bad? This is not a constant flowing stream. This is basically a pond that overflows occasionally into the Transquaking River and in that pond are the nutrients.” Mr. Richardson reiterated, “My authority is only to deal with the permitting process.”
A draft permit will follow this informational meeting. More meetings will follow the draft permit, then a public hearing and review before a final permit is issued. Opponents to the final permit can go to court for a judicial review.